subcontracting reporting - nc sbtdc•data for isrs is cumulative. ssrs are based on annual...
TRANSCRIPT
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Subcontracting Reporting
Diane G. Dempsey
May 28, 2015
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Introduction
All Government contractors holding a contract
containing the FAR Clause 52.219-9 Small Business Subcontracting Plan and, with a value in excess of $650,000 ($1.5 m for construction of any public facility with further subcontracting possibilities), must report Individual Subcontracting Reports (ISR) semi-annually and Summary Subcontracting Reports (SSR) annually.
These reports provide the Government Customer with a means to evaluate the utilization of Small Businesses on each contract.
Performance data is based on the Government’s fiscal year (October 1 through September 30).
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Types of Reports
Individual Subcontracting Report (ISR)
– This reports records progress against the proposed subcontracting goals on a specific contract
Summary Subcontracting Report (SSR)
– The SSR report encompasses all Government contracts held by a Contractor whether or not it contains a subcontracting plan
– ALL DoD Contractors submit the SSR annually at the end of the Government fiscal year
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What Data Is Reported?
Data reported is limited to first tier subcontracting
However, the following exceptions apply:
1) Contractor or subcontractor has been designated to receive SB or SDB credit from ANC or Indian Tribe – which are large entities.
2) Purchases from affiliate of contractor or subcontractor are excluded from base
Note: Subcontracts by first tier affiliates of the prime Contractor shall be treated as subcontracts of the prime Contractor
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Where is the Data Reported?The main reporting portal is Electronic Subcontracting Reporting System affectionately known as eSRS
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Report Schedule
Mid-year reports are due 30 days after the end of the first reporting period (Oct 1 through Mar 31), which is April 30
and
Year-end reports are due 30 days after the end of the second reporting period (Apr 1 through Sep 30) which is October 30/1st.
Due!
Due!
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Which Report When?
Contractors reporting on DoD or Civilian Agency contracts under an Individual or Master Subcontracting Plan report semi-annually
ALL DoD Contractors submit the SSR annually at the end of the Government fiscal year (This is a change from semi-annually based on a
DoD Class Deviation issued Sept 9, 2013)
Contractors under the Comprehensive Test Program report semi-annually
Commercial Plan holders report annually via the SSR at the end of the Government’s fiscal year
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ISR Reporting
• Separate report for each individual contract with a subcontracting plan
• Submitted semi-annually
• Data reported as cumulative during the life of the contract as purchased from US firms.
• At the end of contract performance, the final report is sent to the Contracting Officer as a performance record within 30 days of contract completion
• Timeliness and accuracy of the report are critical
• Reports are deliverables under the contract
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Example of an ISR Report
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SSR Reporting
• SSR reports include all spend, direct and indirect, on all contracts with the US Government regardless of whether the contract has a subcontracting plan
• If work performed is for more than one executive agency, a separate report is submitted to each agency covering only that agency’s contracts.
• For DoD, a consolidated report is submitted for all contracts awarded by military departments/agencies and/or subcontracts awarded by DoD prime contractors
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Example of an SSR Report
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SSR – Commercial Subcontracting Plan
• Report includes all subcontract awards under the commercial plan
• If working for more than one executive agency, specify the percentage of dollars attributable to each agency from which contracts for commercial items were received
• Authority to acknowledge or reject the SSR is the Contracting Officer who approved the Commercial plan
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Commercial/Industry Reporting
Customers may require spend reporting:
• Monthly
• Quarterly
• Semi – Annually
• Annually
• Contract Completion
MBE/WBE/VBE/DOBE/LGBT Spend may be included
Be sure to READ THE CONTRACT
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Summary
• Submit a report for all contracts with subcontracting plans.
• Check subk plan to determine when to submit reports.
• Data for ISRs is cumulative. SSRs are based on annual spend/commitments
• A final ISR must be submitted after contract completion (one full reporting period after PoP ends).
• Submit reports on time – corrections via a revised report may be submitted later.
• Reports are considered contract deliverables.